Anti-Money Laundering & Financial Crime Policy

1. Our Approach
We apply a risk-based approach to compliance and ensure appropriate due diligence is
conducted before entering into any commercial agreement.

Our internal procedures are designed to:

• Prevent money laundering and financial crime

• Verify the identity of all counterparties

• Ensure funds originate from legitimate source

• ​Comply with UK regulatory and legal standards

2. Customer Due Diligence (KYC)
Before entering into any agreement, we conduct structured due diligence on all clients.
We only onboard:

• UK-registered limited companies

• UK-based sole traders
   

As part of our onboarding process, we may collect and verify:

• Full legal name and company details

• Companies House registration information

• Director identification

• Proof of address

• Business bank account verification

• Recent bank statements

• Signed commercial agreements
   

We verify information through Companies House checks, identity review, bank account
confirmation, and open-source screening.

No agreement proceeds without satisfactory completion of our due diligence process.

3. PEP & Sanctions Screening
We conduct screening procedures to ensure we do not engage with sanctioned individuals or
entities.
This includes:

• Screening against UK financial sanctions lists (including HM Treasury / OFSI)

• Open-source checks for politically exposed persons (PEPs)

• Review of publicly available records
   

We do not knowingly conduct business with sanctioned individuals, entities, or jurisdictions.

4. Underwriting & Risk Assessment
All commercial agreements are subject to internal assessment prior to activation.
This includes:

• Review of trading history

• Verification of operational activity

• Assessment of repayment structure

• Internal approval procedures
   

Amounts advanced or structured under agreement are subject to status and internal review.

5. Ongoing Monitoring
We maintain ongoing monitoring throughout the business relationship, including:

• Payment performance monitoring

• Review of structural changes via Companies House

• Monitoring for unusual or suspicious activity

We reserve the right to suspend or terminate agreements where compliance concerns arise.

6. Data Protection
TL Group Holdings LTD is registered with the UK Information Commissioner’s Office (ICO)
under reference number ZC094125.

We process personal and business data in accordance with:

• UK GDPR

• The Data Protection Act 2018
   

Data is collected solely for underwriting, contractual, compliance, and payment processing
purposes.

All data is stored securely, access is restricted to authorised personnel only, and records are
retained in line with UK legal and regulatory expectations.

7. Reporting & Compliance Oversight
Compliance oversight is maintained at director level.

If suspicious activity is identified, we reserve the right to:

• Decline applications

• Suspend collections

• Terminate agreements

• Seek appropriate professional or legal guidance